USACE Replies to Miami Waterkeeper and Partners' Comments on Back Bay Study

For an update on this issue, check out or July 2020 Action Alert here.

Properties throughout South Florida are continuing to face the reality of rising sea levels and storm surge. Increased flood frequency levels and inundation are becoming the norm -- threatening neighborhoods to the east and west of Biscayne Bay. Local municipalities and governmental agencies are beginning to strategize and plan for a “sea-level rise ready” community. The U.S. Army Corps of Engineers is currently making headway on the planning stages of the Miami-Dade Back Bay Coastal Storm Risk Management Study. The Corps is examining projects through two studies: one looking at the eastern or ocean side of the Bay, and one to the western coast, including a highly urbanized part of Miami. This study aims to consider flood-prone areas in the county such as Little River, Miami River, Cutler Bay, Arch Creek, and Aventura. Projects range from installation of seawalls, artificial breakwaters, and often concrete structures to absorb wave action, commonly referred to as “grey infrastructure." 

Heavy flooding in downtown Miami (Source: Carl Juste/Miami Herald)

After in-depth review and research, Miami Waterkeeper commented in January 2019 that this $3 million study seems to prioritize economic interest over community or environmental benefit. In addition, Miami Waterkeeper, Catalyst Miami, and the Miami Foundation submitted further comments to the Corps in October of 2019 regarding additional inequitably elements of proposed projects. And in May of this year, the Corps replied to our areas of concern. 

Comment Letter - Miami Waterkeeper

Miami Waterkeeper’s initial recommendations to the Corps called for completing an Environmental Impact Study (EIS) rather than an Environmental Assessment (EA), prioritizing natural and nature-based features (NNBF) as part of any risk reduction strategy, and measuring potential benefits in an equitable way that is not simply based on real estate values. The comments also highlighted that the Corps should take the unique geological and hydrological characteristics of South Florida into account.

Read the January 2019 technical comments HERE and HERE.

The Corps responded in June 2020 saying that “[t]he document has been prepared as an integrated feasibility study/programmatic EIS. The term “programmatic” indicated this is a broad or high-level NEPA document and not a site-specific NEPA document.” With respect to our recommendation to prioritize Natural and Nature-Based Features (NNBF), the Corps said there is potential for mangrove restoration in Cutler Bay and this option will be evaluated further. Lastly, the Corps stated, “The feasibility study considers a 10% level of design with technical reviews of the report conducted by experts from various disciplines including engineering and that more detailed analysis and design will occur in later phases of the project.”

Read the full response HERE. 

Comment Letter - Miami Waterkeeper, Catalyst Miami, and Miami Foundation

Miami Waterkeeper, Catalyst Miami and the Miami Foundation further expressed the following comments of concern: 1) ensure projects will do no harm to existing communities and infrastructure; 2) define and expand community vulnerability considerations; 3) expand the review of critical infrastructure; 4) focus on projects with multiple benefits; 5) focus on the proposals with local support; 6) evaluate green infrastructure projects. 

Read December 2019 full comments HERE.

The Corps’ responded to our comments in June 2020 with the following:

1. “These structural measures of grey infrastructure would reduce flood risk for a large number of structures and provide life-loss benefits. There is no ideal location for a structural measure to be implemented in a fully developed urban area; however, the USACE seeks to minimize impacts to existing neighborhoods and resources.”
2. “7 focus areas are developed based on both coastal flooding and social vulnerability — using the Center for Disease Control and Prevention’s Social Vulnerability Index (SVI) including census data based on socioeconomic status, household composition, minority status, and language, and housing and transportation. 
3. “...Critical infrastructure will include fire stations, medical facilities, police stations, evacuation centers, wastewater, and potable water facilities, emergency operation center facilities, etc. …As the study progresses, we may also consider the full extent of 0.2% floodplain.”

4. These measures [storm risk management alternatives] are formulated to reduce risk to residents, industries, businesses, and infrastructure, all of which are critical to the nation’s economy.

5. “Measures are identified with stakeholder input and then screened to meet study objectives while avoiding planning constraints.”

6. “The potential for mangrove restoration in Cutler Bay was determined to be the most feasibly and cost-effective NNBF measure for this project and will be included in the draft plan."

Read full response HERE.

High-value properties are more likely to benefit from the above protection features, often at the expense of historically vulnerable communities. In addition to constructing various entities of “grey infrastructure,” the Corps may also recommend elevating homes that are vulnerable to inundation or buying out land in these often lower-income areas. These buyouts underscore environmental justice concerns given that certain communities are already beginning to absorb the cost of climate gentrification, and will only face added pressure with the Corps’ agency actions. An Executive Order requires the Corps to equitably address environmental impacts on minority populations -- requiring nondiscriminatory enactment of storm risk mitigation strategies. Flooding, and its ability to present a public health risk, see no boundaries; all communities can and will be affected throughout South Florida. 

Read more on the Miami Back Bay Feasibility study HERE.